Transfer of merchant portfolio

We advised an authorized payment institution in:

Transfer of merchant portfolio

The global merchant payment processing market is very mature. It is not uncommon on it to “transfer” part or all of a merchant’s portfolio from one clearing agent to another. DLK once again advised on this type of transfer. The transfer brings full business value if the new agent is not only the merchant’s supplier, but maximally takes over the legal situation of the previous agent at least in terms of AML (KYC), access to historical transactions, personal data.

DLK’s advisory included:

• evaluation of the activities included in the transfer
• assessment of the admissibility of processing users’ personal data by the new clearing agent
• rights and obligations of the new settlement agent in terms of AML, professional secrecy, personal data, including so-called silent parties